( June 17, 2026, 10:44 AM EDT) -- CINCINNATI — A captive insurance manager told the Sixth Circuit U.S. Court of Appeals that a Tennessee federal judge erred in upholding an IRS final rule governing small captive insurance arrangements because the rule treats legitimate captives as abusive or potentially abusive tax-avoidance transactions without a sufficient abuse finding and relies on inadequately explained taxpayer examinations, loss-ratio and financing factors and continuing disclosure requirements....